By: Patrick Kissel

View/Download PDF Version: ICE Must Use Front Plates, Cannot Use Out-of-State Plates in Minnesota (Kissel)

Minnesota has experienced something few predicted an American state would ever experience: a federal occupation. Masked agents of Immigration and Customs Enforcement (ICE) and other agencies of the Department of Homeland Security (DHS) have roamed the streets of Minnesota’s cities and towns, abducting residents under the guise of immigration enforcement.  These agents have harassed Minnesotans who sought to observe these agents, obstructed the delivery of mutual aid, and ultimately murdered two Minnesotans, Renee Good and Alex Pretti, for partaking in these activities. This list of offenses is only a sample of what the federal government unleashed on Minnesota over the course of Operation Metro Surge. While Tom Homan has supposedly brought an end to Operation Metro Surge,[1] federal agents have continued their excesses both in Minnesota and around the country.[2]

One of the features of ICE and DHS activities is their unmarked cars. On the ground, ICE cars rarely bear markings indicating that federal agents are operating them. License plates are either missing or obscured, switched from another car, or altered to reflect a different license plate number than that actually displayed on the plate.[3] Many lack any front plate, and almost none have government plates.[4] One common question, particularly on the ground among Minnesotans organizing against ICE, is whether these vehicle identification practices comply with the law. Given the prolificness of DHS vehicles having no, obscured, or altered plates, this post answers how the law requires ICE and DHS vehicles be marked and identified.

Regulations promulgated by the Federal Property Management Regulations System govern federal government motor vehicle identification.[5] These regulations give a broad meaning to government motor vehicle, defining them as “any motor vehicle that the Government owns or leases.”[6] These regulations require that all government motor vehicles display “For Official Use Only,” “U.S. Government,” and identification readily identifying the agency that owns the vehicle.[7] Additionally, government motor vehicles must use U.S. Government license plates,[8] and be registered with Federal Government Motor Vehicle Registration System.[9]

The regulations do exempt some vehicles from these standard identification rules in two ways. First, the head of an agency or a designee may give a limited exception for three days to three years upon showing that identifying the vehicle would “endanger the security of the vehicle occupants or otherwise compromise the agency mission.”[10] Alternatively, vehicles “used primarily for investigative, law enforcement, intelligence, or security” have an unlimited, automatic exception.[11] But vehicles exempted from standard  identification rules are not exempted from all licensing requirements; those exempted must be registered and inspected in accordance with the laws of the state in which it regularly operates,[12] and “display the regular license plates of the State … where the motor vehicle is principally operated.”[13]

ICE and DHS are in clear violation of these rules. The agency either does not identify their vehicles as U.S. Government vehicles or frequently lack proper registration and license plates, as required under Minnesota law which the regulations explicitly require ICE’s vehicles comply with.[14] Minnesota’s laws include displaying both a front and back license plate.[15] Minnesota law also requires license plates be kept “legible and unobstructed and free from grease, dust, or other blurring material so that the lettering is plainly visible at all times.”[16] Additionally, “[i]t is unlawful to cover any assigned letters and numbers or the name of the State of origin of a license plate with any material whatever, including any clear or colorless material that affects the plate’s visibility or reflectivity.”[17] That ICE regularly lacks front plates, or obscures and covers license plates to minimize visibility is clearly and publicly documented.

Also noteworthy is the above-outlined regulations are new, part of a Trump administration overhaul of regulations which took effect in December 2025.[18]  These rules which ICE and DHS have so flagrantly violated are the administration’s own.

One potential hiccup for regulating ICE vehicle identification, however, is that, especially during Operation Metro Surge in Minnesota, ICE has rented many of their vehicles rather than purchase them, primarily from Enterprise.[19] Taking a short visit to the Whipple Federal Building quickly reveals to an observer the number of ICE-operated vehicles operating therefrom with out-of-State plates, likely indicating rentals. The regulations do not provide special rules for leased vehicles. However, the definition of a government motor vehicle explicitly includes leased vehicles together with vehicles the government outright owns.[20] Therefore, they must either have the aforementioned identifying markings and a U.S. Government plate, or be registered in and “display the regular license plates of the State … where the motor vehicle is principally operated.”[21] That State is Minnesota for those operating as part of Operation Metro Surge, and all the rules outlined in the previous paragraph apply to rental vehicles operated by ICE and DS the same as to those owned by them.

ICE’s flagrant violation of the vehicle identification regulations has recently been included in the State of Illinois’ complaint against DHS seeking declaratory and injunctive relief relating to ICE operations in that State.[22] The complaint included specific examples of ICE lacking, obscuring, or altering their license plates.[23] It also makes explicit note of Illinois’ own requirement that vehicles registered in the State display both front and back plates.[24] Yet, despite a month having passed since Illinois filed this complaint, DHS has continued to ignore these regulations in Minnesota.

Minnesota law enforcement must fulfill their role of protecting Minnesotans from lawless actors, which at its most fundamental level requires enforcing the State’s licensing laws. To do otherwise jeopardizes the ability of Minnesotans harmed by ICE to attain justice in the future by making it more difficult to track and identify offending agents. Through the omission of enforcement, Minnesota law enforcement makes it more difficult for communities to identify ICE and act accordingly. Fundamentally, State actors, by failing to enforce even basic vehicle registration and identification requirements, contributes to the undermining of the rule of law.

 

[1] Steve Karnowski & Tim Sullivan, Border czar says Minnesota immigration crackdown is over, after angry protests and 2 fatal shootings, AP News (Feb. 12, 2026), https://apnews.com/article/minnesota-metro-surge-ice-523d18d5d75c81cbf9f24c602f1884ff.

[2] Even with the end of Operation Metro Surge, Tom Homan has confirmed ICE will maintain a presence in Minnesota. Based on the number of officers he has stated are leaving the state, as many as 800 may remain in Minnesota, and that assumes he is wholly truthful in his statements about the size of the drawdown. See Ben Finley, Trump’s border czar says smaller force of ICE agents will remain in Minnesota amid drawdown, PBS News (Feb. 15, 2026), https://www.pbs.org/newshour/politics/trumps-border-czar-says-drawdown-of-ice-agents-in-minnesota-continues-but-smaller-force-will-remain.

[3] For just a selection of non-anecdotal evidence supporting these license plate-obscuring behaviors by ICE, see, e.g., Jana Hollingsworth, Swapped, covered and removed: The license plate tactics ICE is using in Minnesota, Minn. Star Trib. (Feb. 6, 2026), https://www.startribune.com/swapped-covered-and-removed-the-license-plate-tactics-ice-is-using-in-minnesota/601573065; Jon Collins, Minnesota DVS warns ICE agents they’re violating state law by switching license plates, MPR News (Dec. 24, 2025), https://www.mprnews.org/story/2025/12/24/ice-agents-in-minnesota-are-violating-state-law-by-switching-license-plates; Ximena Bustillo & Ailsa Chang, Are ICE agents covering their license plates as well as their faces?, NPR (Oct. 28, 2025), https://www.npr.org/2025/10/28/nx-s1-5501635/are-ice-agents-covering-their-license-plates-as-well-as-their-faces.

[4] Id.

[5] 41 C.F.R. §§ 102.34.85–155.

[6] 41 C.F.R. § 102.34.35 (emphasis added).

[7] 41 C.F.R. § 102.34.85.

[8] 41 C.F.R. § 102.34.95.

[9] 41 C.F.R. § 102.34.120.

[10] 41 C.F.R. § 102.34.155(a).

[11] Id.

[12] Supra, note 9.

[13] 41 C.F.R. § 102.34.155(b).

[14] Supra, notes 9 and 13.

[15] Minn. Stats. §169.79(6) (“If the motor vehicle is [not a semitrailer, motorcycle/two-wheeled motorized vehicle, small trailer, roadable aircraft, or collector’s vehicle], one plate must be displayed on the front and one on the rear of the vehicle.”).

[16] Minn. Stats. § 169.79(7).

[17] Id.

[18] Cf. 41 C.F.R. §§ 102.34.85–155 (2024).

[19] Sarah Fenske & Ryan Krull, Enterprise, other businesses come under fire for connections to ICE, St. Louis Magazine (Feb. 10, 2026) https://www.stlmag.com/news/enterprise-mobility-ice-blues-charter-flights/.

[20] Supra, note 6 (“Government motor vehicle means any motor vehicle that the Government owns or leases.”) (emphasis added).

[21] Supra, note 13.

[22] Complaint for Declaratory and Injunctive Relief at 67–71, Illinois v. Dep’t of Homeland Sec. (2026) (No. 26-cv-321), 2026 WL 93775.

[23] Id.

[24] Id. at 67; 625 ILCS 5/3-413(a).